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#311075 - 02/01/05 05:04 PM HMDA Purpose Unknown
someone else Offline
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someone else
Joined: Aug 2004
Posts: 3,300
back to my roots
I have a loan in front of me that has no documented purpose. All I know for certain is that it is not a refinance as there is no lien to pay off. The loan officer that took the application is no longer employed with us. I cannot tell if we should have even collected the GMI on this application. Is there any solution? Or do I just document the error? It is showing up as an error on my LAR as well. Any and all help is always appreciated!
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Lending Compliance
#311076 - 02/01/05 07:33 PM Re: HMDA Purpose Unknown
upstateNY Offline
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Joined: Apr 2003
Posts: 933
New York State
I would simply take the stand that you cannot report is for HMDA, as the purpose is not known. However, you might want to check to see if it was coded as "home improvement" for example on the bank's books. If not, I'd get it off the LAR.

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#311077 - 02/01/05 07:33 PM Re: HMDA Purpose Unknown
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
If you cannot document the purpose I would remove it from the LAR and document the collection of GMI as an exception.
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#311078 - 02/01/05 08:00 PM Re: HMDA Purpose Unknown
SMQ, CRCM Offline
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SMQ, CRCM
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Between the lines
someone else, just for argument sake, it may be possible that it is a refinance. Not sure from your post, but if you are only looking at your bank for a previous loan, just a reminder here that they may be refinancing a loan that was held at another bank.

Can you determine how the proceeds were disbursed? If that doesn't tell you anything new, I agree that you should remove from LAR.
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#311079 - 02/01/05 08:05 PM Re: HMDA Purpose Unknown
someone else Offline
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someone else
Joined: Aug 2004
Posts: 3,300
back to my roots
Trust me on this one, I have looked at every angle. I have looked over the credit reports and there are no existing liens. It is not coded as HI anywhere, not on the application, not in the memos and not on our software. And, since these were canceled/denied, most of them do not have settlement statements to show if any of the proceeds were going to the purchase of another dwelling.

I am going with all your advice. I will remove them from the LAR and document the GMI exception. I don't think there really is any other option.
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Somewhere, something incredible is waiting to be known. - Carl Sagan

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